'Justice not served by following majority sentiments': Supreme Court upholds conviction of actress' boyfriend in her suicide

New Delhi: The Supreme Court on Tuesday said that justice is not served by following majority sentiment or public pressure, rather it is served by truth, established through evidence and impartial investigation.

A bench of Justices Rajesh Bindal and Manmohan said, while public outrage is understandable in high-profile cases, it should never dictate the course of inquiry. Investigations require careful collection of evidence, impartial analysis, and conclusions grounded in fact. 

"Allowing public sentiment to shape outcomes risks miscarriages of justice. A society committed to fairness must recognise that investigators and courts serve the truth, not popularity. Their independence is not a luxury but the foundation of justice itself,'' the bench said.

The court made these observations while upholding the conviction and sentence of two years awarded to Gudipalli Siddhartha Reddy by the Andhra Pradesh High Court for entering into a suicide pact with Pratyusha, famous South Indian actress in 2002, in view of opposition of family members for their marriage, resulting into her death.

The court held that the appellant-accused has abetted the offence under Section 306 of the IPC by purchasing the pesticide with the knowledge of its lethal nature. 

Furthermore, it noted, in absence of any explanation by the accused as to why the deceased and the accused consumed poison would lead to an adverse inference that it was consumed with intent to commit suicide. 

"Suicide in a suicide pact is conditional upon mutual participation of the other. In other words, if not for the active participation of both the parties, the act would not occur. The law treats such conduct as abetment because the State has a fundamental interest in preserving life. Any assistance in ending life is treated as a crime against the State,'' the bench said.  

The court held that the accused’s conduct in entering into and acting upon the suicide pact fell squarely within all the three situations envisaged in Section 107 of the IPC. 

"His participation directly facilitated the deceased’s suicide. Notably, it is not his defence that the deceased was the dominant personality who pressured him into the pact. His culpability therefore stands established,'' the bench said, directing him to surrender within four weeks to serve the sentence.

The High Court in the case reduced the sentence from five to two years jail. 

The deceased Pratyusha had acted as a heroine in a number of feature films in South India. The appellant-accused was an engineering student. They had known each other close to a decade and wanted to marry each other.   

In view of opposition to their marriage by the appellant's mother and threat of suicide, it was alleged both of them had on February 23, 2002 consumed poison and were admitted in a hospital in Hyderabad. The deceased could not survive and passed away the next day. The appellant survived and got discharged on March 9, 2022.

The matter was subsequently handed over to the CBI for probe. In its judgment, the court came down heavily on Dr B Muni Swamy, who without any authorisation conducted the postmortem examination of the deceased, and claimed before the media that she died of manual strangulation and that she was gang raped.

On the CBI's request, a committee of doctors of AIIMS Delhi was constituted which gave its report that the cause of death was Organophosphate poisoning and the external injuries were caused due to therapeutic procedures which were misinterpreted as injuries due to manual strangulation in the postmortem report.

Finding the conduct of Dr Muni Swamy in contempt of court, the bench opined that the impact of a doctor issuing an erroneous postmortem report and publicising it through the media goes far beyond individual misconduct. 

"It spreads misinformation, erodes trust in investigative agencies and institutions such as the police and judiciary, prejudices public opinion, traumatises the victim’s family, and undermines the rule of law. Such misconduct does not merely harm one case; it corrodes public trust in medicine, law, and governance, destabilising peace and harmony in society. It also violates the sub judice rule, which restricts commentary on matters under judicial consideration to preserve fairness and integrity,'' the bench said.